Zen Global Privacy Policy

1. Introduction

1.1. Zen Global has a commitment to privacy in accordance with The Privacy Act 1988

(Australia) (the Privacy Act), and is committed to protecting and maintaining your

privacy.

1.2. In this policy “we”, “our”, “us” or “company” means Zen Global Pty Ltd ACN 128 138

045.

1.3. We understand that when interacting with us the privacy and confidentiality of your

personal information is important to you. That is why we are committed to safeguarding

your personal information.

2. Purpose of this Policy

2.1. This Privacy Policy describes the types of personal information we may collect, and

how we use, hold and disclose this personal information.

2.2. This Privacy Policy also sets out how you can contact us to access or correct your

personal information or make a complaint.

2.3. By providing personal information to us, you accept and consent to our collection,

storage, use and disclosure of your personal information in accordance with this Policy.

2.4. Section 13 of this Policy provides details on how to contact us in relation to privacy

requests, inquiries or complaints.

3. Definitions and Interpretation

3.1. For the purposes of this Privacy Policy, "personal information" is defined as

information or an opinion relating to an individual which can be used to identify that

individual.

3.2. This Privacy Policy includes examples but is not intended to be restricted in its

application to such examples. Accordingly, where the word ‘include’ or 'including' is

used, it will mean 'include/including without limitation'.

4. How is personal information collected?

4.1. The types of personal information the Company collects will vary depending on the

nature of your dealings with the Company. You may deal with the Company directly, or

the Company may have your personal information because you are a customer or

member of one of our clients.

4.2. Generally, the types of personal information we collect and hold may include your

name, contact information including phone number, address and email address,

demographic information (age, gender etc), loyalty card numbers, and other information

related to your purchases and transaction history with us or our clients.

4.3. We may collect personal information in a number of ways, including:

a) directly from you, including through our websites, by telephone and through

written correspondence;

b) from publicly available sources of information; and

c) from our clients with whom you may do business as a customer or member.

5. How we use personal information

5.1. Except where your consent has been provided, the Company will only use personal

information for the primary purpose for which we collected it (or a purpose related to it),

where required or permitted by law, or where you have consented to such use or

disclosure.

5.2. The main purposes for which we may use or disclose personal information include:

a) to provide products and services requested by you or a business that you are a

customer of, and to manage those services, including to enable customer

service, delivery and billing;

b) meeting legal and regulatory requirements; and

c) to directly promote and market products, news, promotions and other services to

you where we have your express or implied consent. If you do not wish to receive

news, offers and promotions, we will not contact you about these once you have

advised us as such.

5.3. We may also use your personal information to conduct our business and assist our

clients to conduct their business, help us and our clients manage and enhance their

products and services, create personal profiles in our databases, analyse and report on

and aggregate your personal information for various purposes such as benchmarking,

market research and product and service analysis.

5.4. We may expressly communicate to you the primary purpose for which your personal

information is collected, or it may be clear from the nature of our dealings with you.

5.5. If you receive electronic communications from us, we will provide you with an

opportunity to unsubscribe from receiving further information from us.

6. Our disclosure of personal information

6.1. Except as set out in this Privacy Policy, the Company will not disclose personal

information outside of the Company. The Company will only disclose personal

information to third parties where it is necessary or compulsory to do so.

6.2. The primary instances where the Company may disclose personal information to third

parties include:

a) to external advisors and service providers including advertising and payment

services providers, so they can provide the services we have contracted to them;

b) to law enforcement bodies, in order to comply with the law or to protect the rights,

property or safety of the public or the Company; and

c) if the personal information we hold about you was provided by one of our clients,

and they either request your personal information or they request we provide your

personal information to a third party service provider that they use.

6.3. In certain circumstances we may be a credit provider to you. In these circumstances,

we will handle your credit information in accordance with this Privacy Policy.

7. How is my personal information stored and kept secure?

7.1. The Company takes reasonable physical and electronic steps to keep the personal

information we hold secure from unauthorised access, modification, loss and

interference.

7.2. The Company has internal policies, procedures and systems in place to ensure

compliance with this Policy.

7.3. Personal information may be stored electronically and/or in hard copy, and appropriate

information security measures are in place to protect this information.

7.4. Unfortunately, no data transmission over the internet can be guaranteed to be fully

secure and you need to be aware of this when communicating with or providing

personal information to the Company over the internet.

7.5. Additionally, we ensure that we only disclose your personal information to third parties

where it is necessary or compulsory to do so.

8. International use

8.1. The Company operates many aspects of a business which is by its nature international,

and may use global data storage.

8.2. Accordingly, the information that we collect from you may be transferred to, and stored

at, a destination outside of the country in which the information was collected.

8.3. It may also be processed by employees operating outside of the country in which the

information was collected for one of our suppliers or agencies.

8.4. The Company may disclose or transfer your personal information where necessary to

companies which are “related bodies corporate” or “ultimate holding companies” or

“subsidiaries”.

8.5. When possible, we will ensure that an international entity is bound by privacy

obligations equivalent to the Privacy Act, before we disclose or transfer your personal

information to it.

8.6. By submitting your personal information, you agree to this transfer, storing or

processing. We will take reasonable steps to ensure that your personal information is

treated securely and in accordance with this Privacy Policy.

9. Accuracy of my personal information

9.1. We take all reasonable precautions to ensure that the personal information we collect,

use and disclose is accurate, complete and up-to-date.

9.2. However, the Company will assume that any of the personal information provided by

you is up to date and complete at the time it is provided.

9.3. The Company does not undertake to check or verify the accuracy of personal

information provided.

10. How do I access and correct my personal information, or ask for it

to be deleted

10.1. If you wish to access or update your personal information held by the Company, you

need to contact our Privacy Officer. Please see our contact details in section 13 of this

Policy.

10.2. When you contact us with such a request, we will take steps to update your personal

information, provide you with access to your personal information, delete your personal

information and/or otherwise address your query within a reasonable period after we

receive your request.

10.3. Sometimes it will not be possible for us to grant you access to your personal

information that we have about you, or fully delete all personal information that we have

about you. In such cases, we will give you a written notice explaining why.

10.4. You have the right to ask us not to process your personal information for marketing

purposes.

10.5. If you contact us to modify or delete your personal information and it was originally

provided to us by one of our clients, then your request will be processed in our systems

only and will not modify or change your personal information held by that client. You will

need to contact any third parties who provided us with your information directly and

follow the procedures in their own privacy policy, in order to modify or change the

personal information that they hold about you.

11. How do I make a complaint?

11.1. A complaint regarding a breach or possible breach of privacy must first be submitted in

writing to the Company Privacy Officer. Please see our contact details in section 13 of

this Policy.

11.2. If we are unable to satisfactorily resolve your concerns about our handling of your

personal information, you can contact a regulatory body including the Office of the

Australian Information Commissioner.

12. Policy variations

From time to time, our information handling processes will be reviewed and updated, and we

will update this Privacy Policy accordingly. The Company will notify you of any updates to this

effective immediately upon posting.

13. How to contact us

13.1. If you wish to access or correct your personal information held by the Company, or to

complain about a possible breach of privacy, enquiries should be directed to the

Privacy Officer as follows:

a) BY EMAIL: finance@zenglobal.net

b) BY POST: Privacy Officer, Zen Global, 128 Rose Terrance,

Wayville SA 5064

c) BY PHONE: (08) 8123 3460

13.2. If you no longer wish to receive promotions or other direct marketing communications

from the Company, please contact us through one of the methods stated above to

advise us of such and provide sufficient information to enable us to locate your

information. In some cases, our communications with you may contain specific

methods to opt out of direct marketing material sent via the communication.

14. What other privacy terms may apply

There may be additional privacy notices and terms relevant to you depending on the nature

of your dealings with us and our clients. There are additional privacy terms in our clients’

loyalty programs and for use of our clients’ websites, which we may provide services in

relation to. This policy does not apply to those programs and sites, and you should refer to

the terms of those websites or businesses for more information about how they collect, use,

store and manage your personal information.